delete New Schedule to be inserted in the Merchant Shipping (Prevention of Air Pollution from Ships) Regulations 2008
These are the Merchant Shipping (Prevention of Air Pollution from Ships) (Miscellaneous Amendments) Regulations 2019, which amend the 2008 Regulations to implement MARPOL Annex VI requirements. They introduce IEE (International Energy Efficiency) Certificate requirements for ships of 400+ GT, mandate Ship Energy Efficiency Management Plans (SEEMP) specific to each vessel and kept on board at all times, require fuel consumption data reporting for ships of 5,000+ GT, and establish enforcement mechanisms including detention powers and offences for non-compliance. The regulations also update related definitions and cross-references.
While implementing MARPOL Annex VI, these regulations impose certificate-and-survey bureaucracy that adds compliance costs with dubious marginal environmental benefit. The SEEMP requirement is essentially a paperwork mandate requiring ships to document energy efficiency plans they would likely develop anyway for operational efficiency. The IEE Certificate regime adds yet another layer of government-imposed administrative burden that drives up shipping costs — costs ultimately passed to British consumers and exporters. International shipping competition means ships won't simply pollute more if deleted; they must still meet IMO standards to operate globally. The fees collected under these regulations create a government revenue interest in maintaining compliance theater rather than genuine environmental outcome.